SW6220802_Add Info_20221101

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ROY COOPER 5 =
Governor E7
ELIZABETH S.BISER
Secretary *Eaf QUAMNVEw x
BRIAN WRENN NORTH CAROLINA
Director Environmental Quality
November 1, 2022
ECLS Global, Inc.
Attn: Johnny Glen Tew, PE
19 North McKinley Street
Coats, NC 27521
AND
Jay Ambe Shakti, LLC
Attn: Ankit K. Patel, Member
210 Weaver Forest Way
Morrisville, NC 27560
Subject: Request for Additional Information
Stormwater Permit No. SW6220802
Champs Convenience Store
Harnett County
Dear Mr. Tew and Mr. Patel:
The Division of Energy, Mineral and Land Resources (DEMLR), received a Stormwater
Management Permit Application for the subject project on August 5, 2022. A review of that
information has determined that the application is not complete. The following information is
needed to continue the stormwater review:
1. As designed, the project does not meet Runoff Treatment or Runoff Volume Match. In
order for a project to meet Runoff Treatment, the net increase in BUA must be captured
and treated within one or more primary SCMs (10,890 sf of new BUA is not being
captured/treated) and in order for a project to meet Runoff Volume Match, the annual
runoff volume before development cannot increase by more than 10% (NOTE: This
requirement refers to annual runoff volume, not a flow rate from a design storm). Please
refer to 15A NCAC 02H .1002(43) & (44) and .1003(3)(a). Please ensure that all of the
new BUA (or an area of BUA equal to the net increase in BUA) is being treated in one or
more primary SCMs. If it is not possible to capture and treat all of this new BUA, you
can permit the uncaptured areas as a low-density area (provided it meets all of the low-
density requirements). If it is not possible to permit this area as a low-density area, it may
need to be handled as a variance per 15A NCAC 02H .1003(6) (we can discuss if
needed). Please revise as needed.
North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh,North Carolina 27699-1612
NORTH CAROLINA _
oepm nt of EnvimnmwUl uwl ry 919.707.9200

2. Any off-site components of the drainage area to the SCM that are not diverted around the
SCM need to be accounted for at their full build-out potential (15A NCAC
02H .1003(3)(b)). If off-site areas are not diverted around the SCM, the off-site areas can
be accounted for by either having the Permittee and off-site Property Owner(s) enter into
a legal agreement limiting the amount of BUA/drainage area directed from the off-site
area to the SCM or by assuming that the off-site area is 100% BUA (its full build out
potential), see additional information following these comments. Please revise as needed.
3. Pretreatment provided for an infiltration SCM is provided in addition to, not as part of,
the infiltration SCM. For example, if you are using the isolator rows to function as
forebays for the infiltration SCM, the surface area and storage volume provided by these
isolator rows cannot be used as part of the infiltration SCM, they must be excluded.
Please revise as needed.
4. As designed, the infiltration SCM does not appear to be adequate. The design volume for
an infiltration SCM is typically the volume that can be stored above the bottom of the
SCM (328.0' in this case) and below the lowest bypass elevation (6" weir @ 333.4'). Per
the provided stage-storage table (NOTE: Please provide the rest of this table, the table
does not show any information for elevations below 329.33') indicates that a storage
volume of approximately 15,000 cf is provided at elevation 333.4'. Using Equation 2 in
Part C-1 of the Manual, the minimum required surface area for this SCM would be
approximately 8,333 cf(FS = 2.0, DV = 15,000 cf, K= 0.6 in/hr, &t=72 hrs) while only
4,189 sf are provided (a 4,189 sf bottom area can only support a design volume of
approximately 7,500 cf while a design volume of 10,053 cf was used). Please revie as
needed. NOTE: The minimum required drawdown time is 72 hrs (48 hrs are used in the
calculations)per Infiltration MDC 5 and the factor of safety must be included in the
calculations (a factor of safety of 2.0 or higher should be used, especially given the low
infiltration rate of the underlying soils (as low as 0.352 in/hr during some of the tests per
the soils report)).
5. The minimum required design volume for the SCM should be calculated based on the
drainage area to the SCM, not the project site area (15A NCAC 02H .1050(1)). Please
revise as needed.
6. Since this project is located within a water supply watershed (in addition to a HQW area)
please ensure that Harnett County is also reviewing this project. You will need to receive
approval from both jurisdictions prior to building BUA on-site.
7. Please correct the following issues with the Application (NOTE: Additional items may
need to be corrected on this form depending on how earlier comments are addressed):
a. Section IV, 10—The information in this table should correspond to the DA 1
Column on the Drainage Area Page of the Supplement-EZ Form (it should be an
accounting of the drainage area to the SCM, not the entire site).

b. Section IV, 11 —Please indicate how the off-site impervious areas were
determined (see earlier comment).
8. Please correct the following issues with the Supplement-EZ Form (NOTE: Additional
items may need to be corrected on this form depending on how earlier comments are
addressed):
a. Cover Page:
i. Line 7 —Please provide this item. It is noted that there are no surface
waters located on-site, however this value should be provided. Please refer
to 15A NCAC 02H .1003(4) & .1021(7).
b. Drainage Areas Page:
i. Line 20— See earlier comment. Please revise as needed.
c. Infiltration Page:
i. Line 2—
ii. Line 3 —This item is required per General MDC 1 (15A NCAC
02H .1050(1)).
iii. Line 16—This item is required per General MDC 13 (15A NCAC
02H .1050(13)). If you are seeking a variance (per 15A NCAC
02H .1003(6)), please let me know.
iv. Line 20— See earlier comment.
v. Line 27 — See earlier comment.
vi. Line 31 —As noted earlier, the bypass elevation appears to be at elevation
333.4 ft. Please revise as needed.
vii. Lines 32-33 & 34-43 —Infiltration SCMs of this type are permitted as
infiltration trenches. Please fill out Lines 34-43 (answer the items that you
can and provide an explanation in the Additional Information section for
those that you cannot).
viii. Line 44— See earlier comment. This item should correspond with Line 20
on the Drainage Area Page.
9. Provide PDFs of all revisions, 2 hardcopies of revised plan sheets, 1 hardcopy of other
documents, and a response to comments letter briefly describing how the comments have
been addressed.
a. PDFs must be uploaded using the form at:
https:.//edocs.deq.nc.gov/Forms/SW-Supplemental-Upload
b. Hard copies must be mailed or delivered to the following address:
i. For FedEx/UPS:
Jim Farkas
512 N. Salisbury Street, Office 640E
Raleigh, NC 27604
ii. For LISPS:
Jim Farkas
1612 Mail Service Center

Raleigh, NC 27699-1612
iii. Hand Delivery:
Please reach out to me prior to hand delivering a submission to make
sure that I (or someone else in my group) will be able to receive the
submission. Do not leave the package in the foyer with the
security guard.
NOTE: Hard copies should not be sent to a Regional Office. Doing so
will delay the review process and the submission package may be lost
while being sent from the Regional Office to me in the Central Office.
While it is not required, it is recommended that the off-site drainage from upstream properties be
diverted around the SCM since the Applicant cannot maintain control over the development of
property that they do not own. If the Applicant elects to account for off-site drainage, the off-site
area must be accounted for at its full build-out potential. This can be done by assuming that the
off-site area is 100% BUA (its full build-out potential) or by having the Applicant and Owner of
the upstream property enter into a legal agreement in which the Owner of the upstream property
agrees to record a deed restriction limiting the minimum/maximum amount of BUA on the
upstream property that will be treated in the Applicant's SCM, the locations and sizes of access
and drainage easements, how construction and/or ongoing maintenance costs will be handled,
maintenance responsibility, a list of legal recourses available to each party should one party fail
to hold up their end of the agreement, and any other related legal issues.
Please note that this request for additional information is in response to a preliminary review.
The requested information should be received by this Office prior to December 1, 2022, or
the application will be returned as incomplete. The return of a project will necessitate
resubmittal of all required items, including the application fee. Please reference the State
assigned project number SW6220802 on all correspondence.
If you need additional time to submit the information, please submit your request for a time
extension to the Division at the contact below. The request must indicate the date by which you
expect to submit the required information. The Division is allowed 90 days from the receipt of
a completed application to issue the permit.
The construction of any impervious surfaces, other than a construction entrance under an
approved Sedimentation Erosion Control Plan, is a violation of NCGS 143-215.1 and is subject
to enforcement action pursuant to NCGS 143-215.6A.
If you have any questions concerning this matter please feel free to contact me at
[e-mail] or(919) 707-3646.
Sincerely,
Jim Farkas

Environmental Engineer
Stormwater Program
cc: Fayetteville Regional Office